Introduction

This testimony is presented on behalf of the Utility Consumers' Action Network (UCAN) by Jeffrey A. Nahigian, Senior Economist with JBS Energy Inc. Mr. Nahigian has over 20 years experience working on energy related issues and has appeared before this Commission on numerous occasions. His qualifications are included in Attachment A to this testimony.

In this testimony, UCAN provides its recommendations for SDG&E's funding request for customer services operations and maintenance (O&M) expenses and capital expenditures as well as some associated requests for funding information technology (IT) expenses also associated with SDG&E's customer service functions. With regard to SDG&E's proposed funding of customer services O&M expenses, UCAN recommends reductions in the following categories:

• SDG&E requests incremental funding for many activities that will no longer be necessary once its approved advanced metering project is fully deployed (2008-2010) and were not consistently considered in SDG&E's AMI business case analysis.
• One-time costs that should be excluded from the forecast because they will not recur over the rate case cycle.
• One-time costs that occur in 2008 that should be amortized over the rate case cycle (for illustration here we used DRA's proposed five-year rate case cycle).
• Incremental costs associated with SDG&E's meter reading workforce that will be eliminated with the deployment of AMI (not included as a benefit in the AMI business case analysis).
• Costs associated with lifting the current moratorium on direct access; and
• Costs associated with accommodating future participants in the Community Choice Aggregation program.